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I may be missing something; maybe a memo published in an earlier year -it's been awhile since I worked small services; but the DoD (and AFFARS) regs still seem to require a 2579 filed for any requirement over $10K.
The publishing threshold under FAR 5.101(a)(2) changed awhile ago, from $10k to $15K (to display in a public place for 10 days; or in lieu of a public notice board, any electronic means, i.e., the GPE FBO -i hear some agencies allow $15 - $25k to be posted on Facebook but that's a different discussion).
On the DD Form 2579 there's a little box (Block 13 - Synopsis Required) where we're supposed to check whether or not a synopsize a requirement: Yes or No. If No, we're supposed to cite the exception to publicizing (it even has a note that reads, "if 'No', cite FAR 5.202 exception").
I have a project that falls within this awkward range of $10K to $15K.
Accordingly, DFARS 219.201(c )(10) requires review for all projects over $10K, and that review must use the DD Form 2579. AFFARS 5319.201(d)(10)( B ) reiterates this requirement for a $10K review on the 2579.
So, to summarize, there's no publishing requirement for contracts valued at, or under $15K. Yet we're required to file a DD Form 2579 for projects above $10K and cite a reference for an exception to synopsize.
I spoke with my Small Business specialist and that person could not provide specific guidance, however; that person does expect me to use a FAR 5.202 exception, or to synopsize the requirement. I don't blame them because the regs seem contradictory but clarification would be nice.
Has anyone experienced this, and what are your solutions?